Free Motion for Extension of Time to Complete Discovery - District Court of Federal Claims - federal

Case 1:02-cv-00796-FMA

Document 60

Filed 05/11/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS INFORMATION SYSTEMS & NETWORKS CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 02-796C (Judge Allegra)

JOINT MOTION FOR AN ENLARGEMENT OF THE DISCOVERY PERIOD The parties respectfully request the Court to grant an enlargement of time of 123 days, to and including September 30, 2006, for discovery in this case. The current discovery deadline is May 30, 2006. This is the parties' first request for enlargement of time for this purpose. The parties have conferred about the discovery that is required and agree that it can be completed within the time period requested. The plaintiff requests that the discovery period be extended due to his unusually heavy work load. Although the undersigned is counsel of record, another attorney was responsible for developing this case. That attorney resigned from ISN in September 2005, and he has not been replaced. During that time, counsel for plaintiff was unable to conduct discovery in this case because of his workload. In addition, counsel for plaintiff has out-of-town obligations during the months of July and August, and he has no ability to have work done on this case during that period. Similarly, counsel for the defendant has been unable to devote attention to this case due to her workload. In particular, in the six and one-half months since the discovery period began, counsel for the undersigned has, among other things, prepared and filed 23 briefs and has had six oral arguments.

Case 1:02-cv-00796-FMA

Document 60

Filed 05/11/2006

Page 2 of 2

For the foregoing reasons, the parties respectfully request the Court to grant their motion for an enlargement of the discovery period to September 30, 2006. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

DAVID M. COHEN Director s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director s/ Norman H. Singer NORMAN H. SINGER Singer & Associates, P.C. 10411 Motor City Drive 7th Floor Bethesda, MD 20817 Phone: (301) 469-0400 Fax: (301) 469-0403 Attorney for Plaintiff s/ Doris S. Finnerman DORIS S. FINNERMAN Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, DC 20005 Phone:(202) 307-0300 Fax: (202) 305-7643 Attorneys for Defendant